"Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in...

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"Stopping Improper "Stopping Improper Payments Before They Payments Before They Start: The Past, Start: The Past, Present, and Future of Present, and Future of Program Integrity in Program Integrity in Illinois". Illinois". December 2, 2010 December 2, 2010

Transcript of "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in...

Page 1: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

"Stopping Improper Payments "Stopping Improper Payments Before They Start: The Past, Before They Start: The Past,

Present, and Future ofPresent, and Future ofProgram Integrity in Illinois". Program Integrity in Illinois".

December 2, 2010December 2, 2010

Page 2: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

PresentersPresenters

Linda Saterfield, Acting Director, Human Linda Saterfield, Acting Director, Human Capital Development Division - IDHSCapital Development Division - IDHS

Richard Martin, Manager, Program Richard Martin, Manager, Program Integrity and Quality Assurance Unit – Integrity and Quality Assurance Unit – IDHSIDHS

Michael Garner-Jones, Training ManagerMichael Garner-Jones, Training ManagerBureau of Child Care – IDHSBureau of Child Care – IDHS

Paul Swaney, Director of Quality Paul Swaney, Director of Quality ImprovementImprovement- Illinois Action for Children- Illinois Action for Children

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HandoutsHandouts

Slide showSlide show

Resource GuideResource Guide

Web Resource ListWeb Resource List

Monitoring instrumentMonitoring instrument

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Introduction

Linda Saterfield

GAO Report

Increased focus on accountability

Page 5: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

History of Illinois CCAPHistory of Illinois CCAP CCR&R System expanded from parent CCR&R System expanded from parent

referrals to include assistance programreferrals to include assistance program

Inclusion of Site Administered programInclusion of Site Administered program

All employment and educational related All employment and educational related child care assistance programs in one child care assistance programs in one agencyagency

Aligned all eligibility to income, service, Aligned all eligibility to income, service, residency and age of childresidency and age of child

Page 6: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

History of Illinois CCAPHistory of Illinois CCAP

State provides standardized policies, State provides standardized policies, procedures, tools and guidelines procedures, tools and guidelines

Contracted agencies encouraged to use Contracted agencies encouraged to use innovation and local resources to innovation and local resources to determine best practices for verifying determine best practices for verifying eligibilityeligibility

State evaluates these best practices and State evaluates these best practices and standardizes for entire programstandardizes for entire program

Monitoring and quality assurance systems Monitoring and quality assurance systems developed to ensure accountability developed to ensure accountability

Page 7: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

Current CCAPCurrent CCAP

Dual delivery systemDual delivery system Certificate Program – 16 CCR&RsCertificate Program – 16 CCR&Rs

Regional management for determination of eligibility Regional management for determination of eligibility and payments to all provider typesand payments to all provider types

Site Administered Program – 44 Contracted Site Administered Program – 44 Contracted Center ProvidersCenter Providers

Centers who determine eligibility for their own Centers who determine eligibility for their own caseloadcaseload

Payment done through IDHSPayment done through IDHS City of Chicago Family Support SystemCity of Chicago Family Support System

200 Delegate Agencies200 Delegate Agencies Case management system of their ownCase management system of their own

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Current CCAPCurrent CCAP Stopping improper payments before Stopping improper payments before

they happenthey happen Lack of adequate number of monitors Lack of adequate number of monitors

and investigatorsand investigators Illinois has lowest ratio of State workers per Illinois has lowest ratio of State workers per

capita in nationcapita in nation Focus on early detection of ineligible Focus on early detection of ineligible

familiesfamilies Dedicated, well trained contract staffDedicated, well trained contract staff Strong state-wide support networkStrong state-wide support network Access to data from other State agencies Access to data from other State agencies

the family may have interaction withthe family may have interaction with Identification of other resourcesIdentification of other resources

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Year 1 IPP ResultsYear 1 IPP Results Prompted focused trainings on problem Prompted focused trainings on problem

areasareas WebinarsWebinars Regional meetingsRegional meetings On-siteOn-site

Policy and procedure reviewPolicy and procedure review Examination of varying interpretationsExamination of varying interpretations High level committees to clarify issues and High level committees to clarify issues and

reduce barriersreduce barriers Refocus on federal guidelines to ensure Refocus on federal guidelines to ensure

program is family friendly, child focused, program is family friendly, child focused, fair to providers and accountablefair to providers and accountable

Page 10: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

Can You . . .Can You . . .

Perplex

the

Presenter?

Page 11: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

Monitoring DataMonitoring Data

Doing more with less.Doing more with less. Annual Annual CCAP Caseload – CCAP Caseload –

Families -155,520Families -155,520 Children -289,256 Children -289,256

16 CCR&Rs monitored - triannually16 CCR&Rs monitored - triannually 44 Site Providers44 Site Providers 50-80 Certificate Providers monitored50-80 Certificate Providers monitored Only 3-4 IDHS MonitorsOnly 3-4 IDHS Monitors Cases referred to BOI and other agencies Cases referred to BOI and other agencies

for investigationfor investigation

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Monitoring MethodMonitoring Method

PhilosophyPhilosophy Sample pullSample pull ToolTool

10 review areas10 review areas Draft reportDraft report Agency responsesAgency responses Final reportFinal report Corrective actions/next stepsCorrective actions/next steps

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IPACS ProcessIPACS Process(Illinois Public Aid Communication System) (Illinois Public Aid Communication System)

The IPACS process uses an array of The IPACS process uses an array of databases to validate the information databases to validate the information provided by all customers at provided by all customers at application and redeterminationapplication and redetermination

The IPACS information is used with The IPACS information is used with other relevant facts in determining other relevant facts in determining eligibilityeligibility

More recent documentationMore recent documentation Pay stubsPay stubs

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IPACS ProcessIPACS Process(Illinois Public Aid Communication System) (Illinois Public Aid Communication System)

Databases are accessible by all Databases are accessible by all CCAP eligibility workers as part of CCAP eligibility workers as part of the Child Care Tracking Systemthe Child Care Tracking System

Staff toggle from one system to Staff toggle from one system to anotheranother

A key factor in identifying issues A key factor in identifying issues in the GAO studyin the GAO study

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IPACS IPACS TANF/SNAP/MedicalTANF/SNAP/Medical

PASDX PASDX (SSA and SSI payment information)(SSA and SSI payment information)

AWVS AWVS (Automated Wage Verification System)(Automated Wage Verification System)

KIDS KIDS (Child Support Enforcement records)(Child Support Enforcement records)

Department of Public Health Department of Public Health (Birth (Birth records)records)

CPS On-Line CPS On-Line (Chicago Public Schools)(Chicago Public Schools)

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IPACS Unearned Income FlowIPACS Unearned Income Flow

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Sample AWVS ScreenSample AWVS ScreenMORE INFORMATION ON NEXT PAGE -- DEPRESS PA1 PAGE 1 04/17/2002 AWVS INQUIRY SYSTEM OF 2 SSNO: XXX XX XXXX YEAR: QTR: CLAIMANT: LAST NAME, FIRST NAME BIRTH: 12/15/1970 STREET ADDRESS SPOUSE: CITY OR TOWN STATE ZIPCODE COUNTY: 200 COOK ALIAS SSNO: CLAIM DATE: 12/31/2000 LATEST CHK: 07/18/2001 WKLY BASIC BEN: 111.00 BENEFIT PERIOD: 12/31/2000 THRU 12/30/2001 DEP ALLOWANCE: 36.00 MAX BEN AMT: 2,886.00 MAX BEN BAL: WK BEN AMT: 147.00 EMPLOYER ID/NAME/PLANT/ADDR/CITY/ST/ZIP ---------- WAGES BY QUARTER ---------- 1/2001 2/2001 3/2001 4/2001 1705724 EMPLOYER NO. 1 000 STREET ADDRESS CITY OR TOWN STATE ZIPCODE 252 92 4205110 EMPLOYER NO. 2 STREET ADDRESS CITY OR TOWN STATE ZIPCODE 1248 PAY DATE AMOUNT WKS PD PAY END-DT | PAY DATE AMOUNT WKS PD PAY END-DT 07/18/2001 147.00 01 07/07/2001 | 07/05/2001 294.00 02 06/30/2001 06/20/2001 294.00 02 06/16/2001 | 06/06/2001 294.00 02 06/02/2001 05/23/2001 294.00 02 05/19/2001 | 05/09/2001 294.00 02 05/05/2001 04/25/2001 294.00 03 04/21/2001 |

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Resource GuideResource Guide Recognized there were questionable Recognized there were questionable

cases that were managed differently cases that were managed differently throughout the Statethroughout the State

Asked CCR&R’s for suggestions on the Asked CCR&R’s for suggestions on the most challenging cases and methods most challenging cases and methods and resources used to resolve themand resources used to resolve them

Developed Resource Guide as a Developed Resource Guide as a supplement to policy manual to assist supplement to policy manual to assist staff with challenging casesstaff with challenging cases

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Resource Guide PhilosophyResource Guide Philosophy Sets standard of being objective when Sets standard of being objective when

determining eligibilitydetermining eligibility Using non-judgmental languageUsing non-judgmental language CCR&R staff determine eligibility; not to CCR&R staff determine eligibility; not to

be investigatorsbe investigators When program violation occurs, it is not When program violation occurs, it is not

the role of staff to determine if the the role of staff to determine if the violation occurred intentionally or notviolation occurred intentionally or not

Promote customer service with a goal of Promote customer service with a goal of helping familieshelping families

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Determining the status and income of Determining the status and income of non-parent adults claimed in the family non-parent adults claimed in the family

unitunitUseful ApproachesUseful Approaches    

The Work Number website to verify client’s The Work Number website to verify client’s employment/income that appeared in AWVS employment/income that appeared in AWVS

www.worknumber.com Agency needs to sign a Agency needs to sign a contract prior to using the WorkNumber. contract prior to using the WorkNumber.

To verify the amount of refund on the reported tax To verify the amount of refund on the reported tax form: form: https://sa1.www4.irs.gov/irfof/lang/en/irfofgetstatus.jspInformation needed to access this feature is a social Information needed to access this feature is a social security number and refund amount. If it has been security number and refund amount. If it has been over six months a submittal date is also needed. over six months a submittal date is also needed.

The website The website www.paycheckcity.com does not provide does not provide information about specific clients rather gives information about specific clients rather gives examples of check stubs that could have been printed examples of check stubs that could have been printed from the website.from the website.

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ExamplesExampleso Application for care from Application for care from

a relative who alleges a relative who alleges custody of child w/o legal custody of child w/o legal guardianship or written guardianship or written consent from either consent from either parent.parent.

o One parent is denied One parent is denied based on income. Soon based on income. Soon after the denial, the after the denial, the other parent applies for other parent applies for care.care.

Useful Useful ApproachesApproaches

o Check child’s SSN in Check child’s SSN in IPACS ACID page 1 to IPACS ACID page 1 to determine if child is determine if child is active in an assistance active in an assistance unit.unit.

o Verify custody by calling Verify custody by calling school to determine who school to determine who is listed as is listed as parent/guardian.parent/guardian.

o If the child attends a If the child attends a Chicago Public School, Chicago Public School, use PF15 for verification.use PF15 for verification.

o If one parent is believed If one parent is believed to be incarcerated check to be incarcerated check IDOC website IDOC website (www.idoc.state.il.us) or for federal prisons or for federal prisons check check (www.bop.gov) for status.for status.

Page 22: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

Additional ToolsAdditional Tools

Quality ReviewsQuality Reviews

TrainingsTrainings

Policy Clarification System/ReportsPolicy Clarification System/Reports

AppealsAppeals

Problem ResolutionsProblem Resolutions

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OverpaymentsOverpayments

Determined during monitoring, quality Determined during monitoring, quality reviews or case work activitiesreviews or case work activities

Letter to responsible partyLetter to responsible party Referral to Bureau of CollectionsReferral to Bureau of Collections Referral to Office of ComptrollerReferral to Office of Comptroller Referral to private collection agenciesReferral to private collection agencies SanctionsSanctions

Page 24: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

Let’s See if We Can . . .Let’s See if We Can . . .

Torment the

Trainer

Page 25: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

Illinois Action for ChildrenIllinois Action for Children

Approximately 48,000 active clients Approximately 48,000 active clients on the Child Care Assistance Program on the Child Care Assistance Program in Cook Countyin Cook County 55% of statewide caseload55% of statewide caseload

Part of the Illinois Resource & Referral Part of the Illinois Resource & Referral AgenciesAgencies

Process over $350M in Child Care Process over $350M in Child Care Assistance Program payments Assistance Program payments annuallyannually

Page 26: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

Internal ControlsInternal Controls

Ensure integrity within our organizationEnsure integrity within our organization Annual ethical conduct agreement formsAnnual ethical conduct agreement forms Annual mandatory training for our 400 staff Annual mandatory training for our 400 staff

on program integrity violation preventionon program integrity violation prevention Anonymous reporting line through Anonymous reporting line through

EthicsPointEthicsPoint Forms foundation of awareness for Forms foundation of awareness for

preventing program violations in Child preventing program violations in Child Care Assistance ProgramCare Assistance Program

Page 27: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

Web-Based ResourcesWeb-Based Resources

Staff are equipped with, and Staff are equipped with, and encouraged to use, web-based encouraged to use, web-based resources including:resources including: Department of Corrections, Bureau of Department of Corrections, Bureau of

PrisonsPrisons IRSIRS Google MapsGoogle Maps Work NumberWork Number Assessor’s OfficeAssessor’s Office OthersOthers

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Program Integrity LeadProgram Integrity Lead

We have a Program Integrity department We have a Program Integrity department devoted to reviewing casesdevoted to reviewing cases Even if you are unable to have a department, it Even if you are unable to have a department, it

is important to identify lead staff to develop is important to identify lead staff to develop consistency.consistency.

Referral mechanisms inside your processing Referral mechanisms inside your processing groups to allow staff to refer cases for groups to allow staff to refer cases for additional reviewadditional review

Best Practice ManualBest Practice Manual Catching issues before they startCatching issues before they start

Page 29: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

GAO InvestigationGAO Investigation

September 2010, Government September 2010, Government Accountability Office (GAO) publishes Accountability Office (GAO) publishes report detailing the results of their report detailing the results of their attempts to gain access to Child Care attempts to gain access to Child Care Assistance in 5 states.Assistance in 5 states.

Illinois was the only state to prevent their Illinois was the only state to prevent their attemptsattempts

Illinois was also the only state tested that Illinois was also the only state tested that uses a Resource & Referral model for uses a Resource & Referral model for processing eligibility of applicants.processing eligibility of applicants.

Page 30: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

Key Factors to SuccessKey Factors to Success

Online ResourcesOnline Resources Staff TrainingStaff Training Internal Alert System to warn other Internal Alert System to warn other

staff of what to look for in staff of what to look for in subsequent attemptssubsequent attempts

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Future of CCAPFuture of CCAP

CCMSCCMS Automated links to other resources to Automated links to other resources to

assist staff/improve timeassist staff/improve time Ad Hoc ReportingAd Hoc Reporting AlertsAlerts Solidifies business flowSolidifies business flow

Review of State systems (IPACS)Review of State systems (IPACS) Revisit policies and proceduresRevisit policies and procedures Time to update best practicesTime to update best practices

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CCMS Program Violation Flow 1CCMS Program Violation Flow 1CCMS-BP-PIQA-006 – CCR&R Suspected Intentional Program Violation

CC

MS

BCC

D/C

usto

mer

Se

rvic

eC

CR

&RC

CTS

No

Check other web sites and resources

Gather appropriate Screen Shots and

Supporting Documentation in CCTS and CCMS

Continue Processing

case

CCR&R Learns of Potential Suspected Intentional Program

Violation

CCR&R Reviews CCMS

and CCTS

Is there a potential intentional suspected

program violation?

Scan documents into

CCMS and Enter Notes into

Case Files

Overpayment Process

Complete Overpayment Referral Form

Is there an Overpayment

Involved?

Yes

Is it during Application Process?

Mark Application Pending

Yes

No

Check CCTS and links for inconsistent

data

Remove Pending

Application Designation

Issue Application Denial

Is it during Application Process?

Yes

No

Page 33: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

Questions and AnswersQuestions and Answers

Page 34: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

Thanks for Attending . . .Thanks for Attending . . .

Page 35: "Stopping Improper Payments Before They Start: The Past, Present, and Future of Program Integrity in Illinois". December 2, 2010.

"Stopping Improper Payments "Stopping Improper Payments Before They Start: The Past, Before They Start: The Past,

Present, and Future ofPresent, and Future ofProgram Integrity in Illinois". Program Integrity in Illinois".

December 2, 2010December 2, 2010